For reasons of readability, the masculine form is chosen for personal designations, but the feminine form is always meant. JITpay™ Financial GmbH (hereinafter jointly referred to as JITpay™) offer their customers (entrepreneurs) the possibility to make use of the central accounting service (billing service) and the pre-financing of claims from deliveries and services (genuine factoring) via access to their internet platform (hereinafter referred to as JITpay™ platform). Both service offerings are closely related and complement each other. In order for you, and thus the company you represent, to be able to make full use of these services, we must continuously collect, process and store data, which may be both personal and non-personal data, as part of the registration process on the JITpay™ platform and for the duration of the business relationship. The protection and security of your personal data is a top priority for JITpay™. Therefore, we strictly comply with the legal requirements:

1. Data protection

We, JITpay™ Financial GmbH, attach particular importance to compliance with data protection laws. The relevant data protection laws, in particular the EU General Data Protection Regulation and the Federal Data Protection Act (new), are fully complied with by us. Personal data is processed exclusively on the basis of the relevant laws and takes place only for the purposes stated under No. 4. The data will only be processed in accordance with the provisions of this privacy policy.

2. Responsible body

The entity responsible for data processing is:

JITpay™ Financial GmbH
Willy-Brandt-Platz 19
38102 Braunschweig

Telephone: +49 531 387 630 10
E-Mail: support@JITpay.eu

Managing Directors: Mr. Dennis Wallenda, Mr. Carsten Koch
Head of IT: Mr. Boris Parke

3. Data acquisition

We collect, store and process the following categories of data in order to fulfill contractual and legal regulations:

• Company data (including the name and address of the client, bank details)
• Personal data (including name, address of the contact person at the client, date of birth)
• Contact data (e.g. telephone number, e-mail address of the contact person)
• Other data (e.g. position of the contact person, transport data, order data, billing data, geodata).

The initial collection, storage and processing of the above data takes place as part of the registration process on the JITpay™ platform.

4. Purpose of the data processing

We process the data mentioned in No. 3 exclusively

• For the fulfillment of the contractual relationship (Art. 6 para. 1 lit b DSGVO) (central accounting or factoring agreement)
• For the fulfillment of legal, judicial or official requirements/orders (Art. 6 para. 1 lit c DSGVO) (e.g. money laundering, credit reports)
• For information about our range of services and events (Art. 6 para. 1 lit a DSGVO)
• To carry out anonymized statistical analysis

5. Data transmission

Data transmission takes place in the following areas:

• Transmission to refinancing partners within the framework of factoring
• Transmission to authorities for the purpose of fulfilling legal requirements (e.g. money laundering)
• Transmission to third parties for the purpose of creditworthiness and identity checks (including Schufa)
• Transmission to clients or contractors within the scope of central accounting
• Marketing purposes
• Business initiation
• Employee data for billing purposes
• Transmission to the JITpay™ Financial GmbH

JITpay™ transmits the collected data, among others, to providers of rating and information services (hereinafter third-party providers) in order to obtain further information, such as the powers of representation, beneficial owners, affiliated companies, as well as data on payment behavior and credit default risk. Our main providers of rating and credit reporting services are listed below:

• Creditsafe Deutschland GmbH, Schreiberhauer Straße 30,10317 Berlin, Germany
• Schufa Holding AG, Kormoranweg 5, 65201 Wiesbaden, Germany
• Verein Creditreform Braunschweig e.V., Saarbrückener Str. 253 A, 38116 Braunschweig, Germany

Furthermore, JITpay™ transmits claims against the customers to banks or financial institutions for the purpose of refinancing, if applicable. For these assignments, the transmission of personal data collected in the registration process or from third parties may be necessary. A transfer of data between the two JITpay™ companies takes place in order to properly provide the joint service offering.

6. Data transfer to a third country

Data transfer to third countries does not take place and is not planned.

7. Deletion periods

The personal data stored by us will be deleted or made anonymous after the purposes mentioned in No. 4 no longer apply or after expiry of any statutory retention periods.

8. Rights of the data subjects

You have the right to obtain information about the data stored by us. Furthermore, you have the right to rectification, deletion, restriction of processing and data portability. To protect your rights (also from No. 7), you can contact us in writing or text form at the following address:

JITpay™ Financial GmbH
Willy-Brandt-Platz 19
38102 Braunschweig

E-Mail: support@JITpay.eu

If you believe that your rights are not being fully respected in the handling of your personal data, you have the right to lodge a complaint with the supervisory authority responsible for you. You have the right to revoke your consent to the processing of personal data at any time with effect for the future. Processing that took place before the revocation is not affected by this.

9. Data protection officer

We have appointed a data protection officer. He can be reached for all questions regarding the protection of personal data via the following contact data: Kämmer Consulting GmbH Phone: +49 531 70 22 49 – 47, E-mail: a.vogelsang@kaemmer-consulting.de

10. Obligation to provide personal data

If you wish to enter into a contractual relationship with us, you must provide the personal data that is required for the fulfillment of the associated contractual obligations or for the collection of which there is a legal obligation. If the data is not provided, no contract can be concluded.

11. Data protection consent

As part of the registration process (establishment of a contractual relationship with JITpay™), you consent to the collection, storage, processing and forwarding of your data by JITpay™ in accordance with this privacy policy. JITpay™ may use this data for the performance of the contractually agreed services in compliance with this Privacy Policy. This consent applies to the initial provision and use of data as well as to all future collection, processing and storage for the duration of an active business relationship with JITpay™. You may revoke your consent to the collection, storage, processing and forwarding of your data by JITpay™ at any time as part of the registration process on the JITpay™ platform. For this purpose, please send a corresponding clear statement to JITpay™ Financial GmbH, Willy-Brandt-Platz 19, 38102 Braunschweig, Germany.

12. Content and Services from Third Parties

The offerings on our website also include content, services, and performances from other providers that complement our offer. Accessing these services from third parties regularly requires the transmission of your IP address. This enables these providers to perceive and store your user IP address. We strive to include only those third-party providers who use IP addresses solely for delivering the content. However, we have no control over which third-party provider may store the IP address. This storage may serve, for example, statistical purposes. Should we become aware of any storage operations by third-party providers, we will promptly inform our users of this fact. Please also note the specific privacy policies of individual third-party providers and service providers whose services we use on our website.

a. Cookies

We use cookies. Cookies are small text files that are stored on your device when you visit the site. They can neither transfer viruses nor malware to your computer but can contain information that allows for user identification.

It is necessary to distinguish between transient cookies, which are deleted once your browser is closed, and persistent cookies, which are stored beyond the session and recognize you during your next visit to the website.

Regarding function, it is necessary to distinguish between technically necessary and non-necessary cookies.

b. Technically Necessary Cookies

Here you will find all cookies that are necessary for the operation of our website and its functions (technically necessary cookies). These are usually set in response to actions taken by you. This includes, among others, registration, login, or settings like language or cookie preferences. It is possible to disable these cookies in your browser. However, a flawless operation of our website can no longer be ensured in this case.

c. Technically Non-Necessary Cookies

Here you will find all cookies that are not strictly necessary for the operation of our website and its functions (technically non-necessary cookies). The use of such cookies constitutes data processing that is only permitted with your active consent (Art. 6 para. 1 sentence 1 lit. a GDPR). This also applies to the transfer of your personal data to third parties.

d. Google Analytics

We use Google Analytics to analyze website usage. The data obtained is used to optimize our website and advertising measures.

Google Analytics is provided to us by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Google processes the data on website usage on our behalf and is contractually committed to measures to ensure the security and confidentiality of the processed data. During your website visit, the following data, among others, is recorded:

• Pages viewed
• Your behavior on the pages (e.g., duration of stay, clicks, scroll behavior)
• Your approximate location (country and city)
• Your IP address (in abbreviated form, so no clear assignment is possible)
• Technical information such as browser, internet provider, device, and screen resolution
• Source of your visit (i.e., via which website or advertising medium you came to us)

Personal data such as name, address, or contact details are never transferred to Google Analytics.

This data is transmitted to Google servers in the USA. We point out that data protection laws in the USA may not guarantee the same level of protection as within the EU.

Google Analytics stores cookies in your web browser for a period of two years since your last visit. These cookies contain a randomly generated user ID, which can be used to recognize you during future visits to the website.

The recorded data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. These user-related data are automatically deleted after 14 months. Other data remains stored in aggregated form indefinitely.

If you disagree with the collection, you can prevent it by installing the browser add-on to disable Google Analytics once or by rejecting cookies through our cookie settings dialog.

Source: traffic3.net

e. Google Maps Plugin

We use a plugin of the Internet service Google Maps on our website. The operator of Google Maps is Google Inc., based in the USA, CA 94043, 1600 Amphitheatre Parkway, Mountain View. By using Google Maps on our website, information about the use of this website and your IP address is transmitted to a Google server in the USA and also stored on this server. We have no knowledge of the exact content of the transmitted data or their use by Google. The company denies the connection of the data with information from other Google services and the collection of personal data in this context. However, Google may transfer the information to third parties. If you disable JavaScript in your browser, you prevent the execution of Google Maps. You will then not be able to use the map display on our website. By using our website, you consent to the described collection and processing of information by Google Inc. For more details on the privacy policy and terms of use for Google Maps, click here: https://www.google.com/intl/de_de/help/terms_maps.html.

f. Open Street Maps

We use map excerpts from OpenStreetMap (https://www.openstreetmap.de/) on our website. OpenStreetMap is an open-source mapping tool. To display the map, your IP address is forwarded to OpenStreetMap. You can view how OpenStreetMap stores your data on the OpenStreetMap privacy page here: https://wiki.openstreetmap.org/wiki/DE:Datenschutz and here: https://wiki.openstreetmap.org/wiki/DE:Legal_FAQ.

We base the use of the aforementioned tools on Art. 6 para. 1 letter f) GDPR: data processing is carried out to improve the user-friendliness of our website and is therefore in our legitimate interest.

g. Facebook Plugin

You will find plugins of the social network Facebook on our website. The provider is Facebook Inc., based in the USA, California 94025, 1 Hacker Way, Menlo Park. The Facebook logo or the “Like-Button” on our site makes the Facebook plugins recognizable. You can find an overview of the Facebook plugins here: http://developers.facebook.com/docs/plugins/. During your visit to our website, a direct connection to the Facebook server is established through the plugin. You are then connected to Facebook through your browser. This informs Facebook that you have visited our website with your IP address. By clicking the Facebook “Like-Button”, you link content from our website to your profile on Facebook. For Facebook, the visit to our site is assignable to your user account. We have no knowledge of the type of content transmitted to Facebook and how Facebook uses it. For more information on data collection and data use, refer to Facebook’s privacy policy here: http://de-de.facebook.com/policy.php. You can prevent the assignment of your visit to our site to your Facebook profile by logging out of your Facebook account beforehand.

h. Instagram Plugin

We also integrate functions of the online service Instagram on our website. The provider of these functions is Instagram Inc., based in the USA, CA 94025, 1601 Willow Road, Menlo Park. The Instagram button allows you to link to your Instagram account when you visit our pages, provided you are logged into Instagram. Instagram thus receives information about your visit to our website and can assign this visit to your Instagram profile. We have no knowledge of the content of the transmitted information or its use by Instagram. For more information on data collection and use by Instagram, refer to the Instagram privacy policy here: http://instagram.com/about/legal/privacy/.

i. Twitter Plugin

Our website also uses functions of the Twitter service. The functions are offered by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. By using Twitter and the “Re-Tweet” function, the websites you visit are linked to your Twitter account and made known to other users. This data transfer also transmits data to Twitter. We, as service providers, inform you that we, as website providers, have no knowledge of the content of the transmitted data or their use by Twitter. Therefore, for more information on the Twitter privacy policy, please refer to the following link: http://twitter.com/privacy.

If you want to change your privacy settings on Twitter, you can do so here: http://twitter.com/account/settings.

j. YouTube

Our website uses plugins from the YouTube site operated by Google. The operator of the site is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you visit one of our pages equipped with a YouTube plugin, a connection to the YouTube servers is established. The YouTube server is informed about which of our pages you have visited.

If you are logged into your YouTube account, you enable YouTube to assign your browsing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

For more information on handling user data, refer to YouTube’s privacy policy here: https://www.google.de/intl/de/policies/privacy.